ACA Reporting Requirements: Your Complete Compliance Guide

Updated February 2026

For Applicable Large Employers (ALEs), ACA reporting isn't optional, it's a federal requirement with real financial consequences. For organizations juggling variable-hour employees, high turnover, or multiple locations, the complexity only multiplies. Every year, employers must document the health coverage they offer, submit forms to the IRS, and furnish statements to employees. Miss a deadline or file incorrectly, and penalties can add up quickly.

This guide breaks down everything you need to know about ACA reporting requirements: who must report, what forms are required, key deadlines, potential penalties, and state-level mandates that may apply to your organization.

What Is ACA Reporting?

ACA reporting refers to the annual filing requirements under the Affordable Care Act that require certain employers to report information about the health coverage they offer to employees. This reporting helps the IRS verify that employers are meeting the employer shared responsibility provisions (also called the employer mandate) and that individuals have qualifying health coverage.

There are two main reporting provisions under the ACA:

• Section 6055 Reporting: Requires providers of minimum essential coverage (including self-insured employers) to report who was covered and when.
• Section 6056 Reporting: Requires ALEs to report whether they offered affordable, minimum value coverage to full-time employees.

Who Must Comply with ACA Reporting Requirements?

ACA reporting requirements apply to Applicable Large Employers (ALEs), organizations that employed an average of 50 or more full-time employees (including full-time equivalent employees) during the prior calendar year.

To determine ALE status:

1. Count all employees who worked an average of 30+ hours per week (full-time employees)
2. Calculate full-time equivalents (FTEs) by dividing total part-time hours by 120
3. Add full-time employees and FTEs together—if the total averages 50 or more across all months of the prior year, you're an ALE
   
   

Important: Smaller employers with self-insured health plans (including level-funded plans) must also report under Section 6055, even if they're not ALEs. They use Forms 1094-B and 1095-B instead of the C forms.

ACA Reporting Forms: 1094-C and 1095-C

ALEs use two primary forms to fulfill their ACA compliance reporting obligations:

Form 1095-C (Employer-Provided Health Insurance Offer and Coverage)

This form is prepared for each full-time employee and includes:

• Employee and employer identifying information
• Month-by-month information about coverage offers (Line 14)
• Employee's share of the lowest-cost monthly premium for self-only coverage (Line 15)
• Safe harbor codes and other relief codes (Line 16)

For self-insured employers, Part III of Form 1095-C also captures information about covered individuals—including dependents and their months of coverage.

Form 1094-C (Transmittal of Employer-Provided Health Insurance)

Form 1094-C serves as the transmittal or cover sheet for all the 1095-C forms an employer submits. It includes aggregate information about the employer: total employee count, whether coverage was offered, and which months the employer was an ALE.

2026 ACA Filing Deadlines

For the 2025 tax year, here are the key ACA reporting deadlines employers must meet in 2026:

Important: You must decide whether you're automatically distributing 1095s to all employees (March 2 deadline) OR posting a notice by January 31 telling employees they can request them. You can't mix approaches.

Note: Most employers must file electronically. The IRS requires electronic filing if you submit 10 or more information returns in aggregate (including W-2s and 1099s).

Alternative Furnishing Method (New for 2025 Tax Year)

Under the Paperwork Burden Reduction Act signed at the end of 2024, employers now have an alternative to automatically mailing Form 1095-C to every full-time employee. Instead, employers may post a clear, conspicuous notice on their website by January 31, 2026 informing employees they can request a copy. If an employee requests their form, the employer must provide it within 30 days. The notice must remain posted through October 15, 2026.

ACA Reporting Penalties for 2026

ALEs face two categories of penalties under the employer shared responsibility provisions:

How penalties are calculated: The 4980H(a) penalty is multiplied by your total full-time employee count minus the first 30. The 4980H(b) penalty applies only for each employee who actually receives a premium tax credit through the marketplace.

2026 Affordability Threshold: For plan years beginning in 2026, employer-sponsored coverage is considered affordable if the employee's required contribution for self-only coverage doesn't exceed 9.96% of their household income (up from 9.02% in 2025).

State-Level ACA Reporting Requirements

In addition to federal requirements, five states and the District of Columbia have their own health insurance mandates with separate reporting requirements. If you employ even one resident of these jurisdictions, including remote workers, you may need to file at the state level.

Important: State reporting requirements operate independently from federal requirements. Even if you use the alternative furnishing method for federal reporting, California, New Jersey, Rhode Island, and Washington D.C. still require you to furnish 1095 forms directly to employees by their respective deadlines.

The ACA Compliance Process

Staying compliant with ACA reporting requirements is an ongoing process, not a once-a-year task, which is exactly why it can feel overwhelming when you're already stretched thin managing day-to-day HR operations. It starts with tracking employee hours year-round, using measurement periods, stability periods, and administrative periods to accurately determine full-time status, especially for variable-hour employees whose hours fluctuate seasonally.

Throughout the year, you'll need to monitor and document coverage offers: which employees received offers, when those offers were made, and the cost of the lowest-premium self-only plan available to them. This documentation becomes the foundation of your 1095-C forms.

Before filing, take time to validate your data. Incorrect Social Security numbers, misspelled names, or wrong codes on Form 1095-C are common errors that trigger IRS penalty letters, and they're entirely preventable with a thorough review process.

Meeting deadlines is critical. Whether you're automatically distributing 1095-Cs by March 2 or using the alternative furnishing method with a January 31 notice, build in buffer time. The same goes for the March 31 electronic filing deadline with the IRS.

Finally, if you receive a Letter 226J proposing penalties, respond promptly. The IRS now gives employers 90 days (up from the previous 30) to respond, use that time wisely to gather documentation and contest any errors.

Simplify Your ACA Compliance

Between tracking hours, managing benefits, and keeping up with constant regulatory changes, ACA compliance can feel like one more thing on an already full plate. Managing measurement periods, safe harbor rules, variable-hour employees, multi-location workforces, and constantly changing regulations doesn't have to overwhelm your HR team. ACA Reporter from Points North simplifies the entire process, from tracking employee eligibility to generating accurate 1095-C forms to filing with the IRS.

With all ACA regulations and tracking rules built directly into the software, you can rest easy knowing your reporting is accurate and compliant.

Learn more about ACA Reporter and see how we can help you stay compliant while saving time.